Guidance

How to report EU sales made on or before 31 December 2020 for VAT

Find out how to report supplies of goods and services to VAT-registered customers in an EU country using an EC Sales List.

Overview

For the export of goods from Great Britain or the supply of services from Great Britain and Northern Ireland made to EU businesses on or after 1 January 2021, you will not need to submit EC Sales Lists.

You will have until 21 January 2021 to submit EC Sales Lists for sales made on or before 31 December 2020.

You’ll still need to submit EC Sales Lists if you sell goods from Northern Ireland to EU VAT-registered customers.

If you’re a VAT-registered business in the UK supplying goods and services to VAT-registered customers in an EU country, you must tell HMRC about those supplies. Use an EC Sales List to show:

  • details of each of your EU customers
  • the sterling value of the supplies you have made to them
  • the customer’s country code

When to complete an EC Sales List

You’ll need to complete an EC Sales List if you are UK VAT-registered, trade from the UK and, on or before the 31 December 2020, have:

  • sold goods to EU VAT-registered customers
  • filled in box 8 of your VAT Return
  • supplied any goods to a VAT-registered business in an EU country (this applies even if you did not invoice for them, unless they count as samples for VAT purposes)
  • moved any of your own goods to a VAT-registered branch, office or subsidiary company that you own in an EU country
  • sold goods to a VAT-registered customer in an EU country and arranged for your supplier, who’s located in an EU country, to send the goods directly to your customer (this is triangulation)
  • supplied services to a VAT-registered EU business before 1 January 2021 and that business is responsible for accounting for the VAT (this is the reverse charge)

If you have moved goods to or from an EU country under call-off stock arrangements, any movements of such stock will need to be reported on your EC Sales List. Any goods that have been returned to you or are now intended for a different customer under call-off stock arrangements will also need to be reported on your EC Sales List. Find out how how to complete your EC Sales List for call-off stock movements.

When call-off stock is called off (sold) under call-off stock arrangements, and the conditions for this treatment are met, the sale should be reported in the same way as you would report any other sale to a VAT-registered business in an EU country and recorded on your VAT return for the period in which the supply was made.

If you have not supplied goods or services to VAT-registered customers in an EU country or issued any credit notes then you do not need to complete an EC Sales List unless you have:

  • sent call-off stocks to an EU country
  • substituted call-off stocks to another customer
  • had call-off stocks returned
  • your call-off stocks have not been sold to your customer within 12 months of arrival in the EU country
  • a relevant event has occurred in relation to your call off stock (see paragraph 10.2 of Changes to tax rules for call off stock arrangements between EU member states for more information)

The simplified EC Sales List

If your business only makes low level supplies of goods to VAT-registered customers in an EU country you may not need to fill in the full EC Sales List. You can contact HMRC to ask if you can send a simplified annual EC Sales List, if:

  • the value of your total taxable turnover in a year is not more than the VAT registration threshold plus £25,500
  • your supplies to customers in EU countries are not more than £11,000 a year
  • your sales do not include new means of transport

You will not be able to report movements of call off stocks using a simplified annual EC Sales List.

If HMRC agrees that you can use the simplified EC Sales List you:

  • never need to fill in the actual value of your supplies to each customer, instead you enter a nominal value of £1
  • complete the form once a year by a date agreed with HMRC

Sending separate EC Sales Lists for different parts of your business

You can choose to send separate EC Sales Lists online if you have:

  • individual branches of your business
  • individual companies within a group VAT registration
  • self-accounting branches within a group VAT registration - contact HMRC to arrange this, you will be given a 3 digit code for each branch or company in your business, you must use this as an identifier when you complete the separate EC Sales Lists

To send data online for individual branches you must register each one separately with HMRC’s Online Services. HMRC services may be slow during busy times. Check if there are any current problems with this service, or times it will not be available.

If the total value of goods supplied from all the branches of your business is more than £35,000 (excluding VAT), in the current or previous 4 quarters, each branch must send a monthly EC Sales List.

How to send your EC Sales List to HMRC

You can send your completed EC Sales List electronically or on paper.

Sending your EC Sales List electronically

You can choose from:

  • ECSL - this is an on-screen form, similar to the paper EC Sales List
  • ECSL ‘bulk upload’ feature as a CSV (Comma Separated Variable) or XML (Extensible Markup Language) file
  • UN-EDIFACT format submissions

If you’re already a registered user of HMRC Online Services, you can enrol for EC Sales List online.

Read the guidance if you’re submitting EC Sales List declarations online using CSVs.

If your EC Sales List includes the cross-border movement of goods or changes of intended customer under the call-off stock arrangements, you will be able to submit this information electronically by:

  • ECSL - this is an on-screen form, similar to the paper EC Sales List
  • ECSL ‘bulk upload’ feature as a CSV (Comma Separated Variable) or XML (Extensible Markup Language) file

You can either send HMRC:

  • a full EC Sales List that includes movements of call-off stock or changes to previously submitted call-off stock information, through one of the above channels
  • 2 EC Sales Lists - one with your EC Sales only, through your usual channel, and the other with movements of call-off stock, or changes to previously submitted call off stock information, through one of the above channels

Sending your EC Sales List on paper

You can download form VAT101 EC Sales List and form VAT101(A) EC Sales List Continuation Sheet

If you’re completing a form VAT101(A) it must always be accompanied by a signed form VAT101.

If you’re using the downloadable forms, you must complete them on screen before printing (single sided) and posting to HMRC. If you want to complete the form by hand, you must use a paper VAT101 available from the VAT Helpline.

Call-off stock information cannot currently be recorded on this paper form. If you are unable to submit call-off stock information electronically contact HMRC at:

HMRC
ECSL Team
BX9 1QT

You do not need to include a street name, city name or PO box when writing to this address.

How often to submit your EC Sales List

The following table covers supplies to VAT-registered customers in EU countries.

Your business supplies The value of your supplies Send your EC Sales List every
Goods is over the £35,000 threshold in the current or 4 previous quarters month
Goods is under the £35,000 threshold in the current or 4 previous quarters quarter
Services that are subject to the reverse charge in the customer’s country on or before 31 December 2020 Not applicable You can only submit this for return periods on or before 31 December 2020 - the final date you can complete a return is 21 January 2021
Goods and services on or before 31 December 2021 where you are required to send monthly lists for your goods Not applicable month for all supplies or goods, and quarter for services - the final date you can complete a return is 21 January 2021

If you make annual returns you can contact HMRC to apply for approval to submit your EC Sales List once a year provided you meet all of the following conditions:

  • your total annual taxable turnover does not exceed £145,000
  • the annual value of your supplies of goods to EU countries is not more than £11,000
  • your sales do not include new means of transport

If you only supply goods (not services) valued at £11,000 or less, the supplies do not include new means of transport and your total taxable turnover does not exceed £93,500 you can also apply to submit an annual EC Sales List.

Deadlines for sending your EC Sales List

You must send your EC Sales Lists:

  • within 14 days for paper submissions
  • within 21 days for online submissions

If you send the EC Sales List in late, you may have to pay a penalty.

How to complete an EC Sales List

Record all the VAT-registered EU businesses you have supplied in the reporting period, entering a line for each customer, for each type of supply.

You must include:

  • their 2 letter country code
  • their VAT registration number
  • the value of the goods and related costs - entering code ‘0’ (zero) in the indicator column - even if you have not invoiced them or been paid yet
  • code ‘2’ in the indicator column if you did not handle the goods yourself and instead, your supplier sent them directly to your customer; this is known as triangulation
  • the value of the services you have provided on or before 31 December 2020, where the place of supply is the customer’s country and the services are subject to a reverse charge - enter code ‘3’ in the indicator column on the EC Sales List for the fourth quarter of 2020

Call-off stock

Where you move goods from the UK to the EU under call-off stock arrangements you must maintain a register with details of call-off stock movements and values for all call-offs up to and including 31 December 2020.

For movements that took place before the end of 2020, if you are trading under the Northern Ireland Protocol you must also continue to record any of the following events on your EC Sales lists if they occur after the end of 2020:

  • changes in intended customer
  • returns of the stock that was moved in 2020
  • call-offs of the stock that was moved in 2020

You can submit the call-off stock information electronically through the EC Sales List online service (see How to send your EC Sales List to HMRC). If you do not submit the information then the EU countries’ tax authorities may decide that the new rules do not apply to you. This could result in your having to become registered for VAT in the EU country the call-off stocks were sent.

When the new VAT rules apply and you move call-off stocks to an EU country you must include the following on your EC Sales List:

  • your intended customer’s 2 letter country code
  • your intended customer’s VAT registration number, in the first VAT registration number field
  • the code ‘4’, for transport of stock, in the indicator column

Leave the ‘total value of supplies’ field blank and do not enter anything in the second VAT registration number field.

If any call-off stock is returned to you under your direction without being called off (sold) during the period of 12 months beginning with their arrival in an EU country. You must record this in your EC Sales List for the period in which the goods were returned and record the return of the goods in your register.

When you return call-off stock to the UK without it having been called off you must include the following on your EC Sales List for the relevant period:

  • your customer’s country code
  • your customer’s VAT registration number, in the first VAT registration number field
  • the code ‘5’, for returned stock, in the indicator column

Leave the ‘total value of supplies’ field blank and do not enter anything in the second VAT registration number field.

If within 12 months of the arrival of the goods in an EU country there’s been a change in the intended customer during a period, you must update your register with details of the substituted goods and you must include the following on your EC Sales List for that period:

  • your original customer’s 2 letter country code
  • your original customer’s VAT registration number, in the first VAT registration number field
  • your new customer’s VAT registration number, in the second VAT registration number field
  • the code ‘6’, for a change of intended acquirer, in the indicator column

Where there is a change in intended customer for call-off stock, do not enter any value of the stock on your EC Sales List.

When call-off stock is called off (sold) the sale must be reported in the same way as you would report any other sale to a VAT-registered business in an EU country and recorded on your VAT return for the period in which the supply was made.

This means that if call-off stocks are moved to an intended customer in an EU country and you make a supply of the goods to the intended customer in the same period you must:

  • record the movement of the call-off stock in your EC Sales List for the period
  • on a separate line, record the sale of goods to that customer

If call-off stocks are not sold within 12 months of arrival in the destination EU country then they have to be treated as being supplied to yourself in the UK and reported as a sale (dispatch) on your EC Sales List. See section 10.1 of Changes to tax rules for call off stock arrangements between the UK and member states for more information on the 12 month rule.

When certain other events occur in relation to your call-off stock (relevant events), the call-off stocks are treated as being supplied to yourself in an EU country and reported as a sale (dispatch) on your EC Sales List. See section 10.2 of Changes to tax rules for call off stock arrangements between the UK and member states for more information.

Zero rating supplies of goods

As long as you meet certain conditions you can zero rate your supplies of goods to VAT-registered customers in EU countries. You must show a valid VAT registration number for your customer on both your customer invoice and your EC Sales List.

You will not be able to zero rate your sales if you have not got your customer’s valid VAT registration number.

Checking EU VAT numbers

Enter your customer’s 2 letter country code and the VAT registration number separately in the appropriate boxes.

Check that your customer’s VAT registration number is valid and that they are actually based in the EU. You’ll need to do this for each new customer.

You can:

When you have confirmed that the VAT registration number is valid, enter it on the EC Sales List. Do not include:

  • spaces, dashes, commas or slashes
  • the 2 letter country code as part of the VAT registration number

Calculating the total supplies to a customer

Add up the value of all the supplies of goods or services you have made in the period rounding down to the nearest whole pound. Enter a separate value for each customer and each type of supply made. You may need up to 3 lines for each customer to show the value of:

  • goods supplied
  • triangular goods supplied
  • services supplied on or before 31 December 2020

Include the:

  • value in sterling, of goods supplied (including related costs, for example, delivery charges) made to each customer, whether you charged for them or not, minus any credit notes issued
  • value of any of your own goods that are moved to your own VAT-registered branch, office or subsidiary company in an EU country
  • value of any services supplied on or before 31 December 2020 that are subject to the reverse charge in an EU country, on a separate line and using code 3 in the indicator box on the EC Sales List for the fourth quarter of 2020
  • value of any triangular supplies of goods, on a separate line and using code 2 in the indicator box
  • value of credit notes issued without making any supplies by entering a minus sign (-) before the amount

Deduct the value of any credit notes you have issued from the value of supplies you report.

Do not include the value of:

  • any goods that have been sent for processing
  • any goods that qualify as samples under the VAT rules

HMRC might have agreed that you only need to complete a simplified EC Sales List because you make low levels of sales to EU customers. If so, you do not need to include the value of the sales you make. Just enter £1 in the value column, not zero.

How to complete your EC Sales List using the online form

If you submit your EC Sales List online you must do so within 21 days of the end of the reporting period.

Use EC Sales List

You must register and enrol for HMRC online services.

When you have registered and enrolled, sign in to EC Sales List using your user ID and password.

Choose ECSL from the list of services displayed, then select the web form option.

It’s important to use the buttons on the ECSL screens to navigate backwards and forwards. If you use your browser ‘back’ button you might lose data.

Entering data

Use 1 line for each customer and for each type of supply. You can get extra lines by selecting the ‘More lines’ button. You might find it’s more convenient to use the bulk upload service if you regularly fill in more than 20 lines.

If you do not enter any information for 15 minutes you will be automatically logged off.

Entering negative values online

You might need to enter a negative (minus) value for your supplies to a customer, for example because you issued a credit note for goods they returned. Type a minus sign ‘-’ before the amount to show a negative value.

Nil returns

ECSL will not let you submit a nil return. So if you have not made any supplies (or issued any credit notes) in the reporting period, do not submit an EC Sales List.

How to submit your form

After you have entered all the information for the reporting period, select the ‘Submit’ button. You’ll be shown a ‘Review and submit screen’ next so you can check over your figures before you finally submit them. The form will be checked automatically on submission and if any errors are found they’ll be highlighted by an ‘X’ on this screen. You will have an opportunity to correct the errors before resubmitting.

Your Submission Reference Number

After you have submitted your form you’ll see an acknowledgement screen. This gives you a unique ‘Submission Reference Number’. Print this and keep it for your records. If you do not get this number you cannot be certain that your form has been received and accepted by HMRC.

Correcting errors

You can correct any errors on your online form, within 21 days of submitting the original declaration.

Logging in and submitting your EC Sales List using bulk upload

Log in to the online service, using your User ID and password. From the list of services choose ECSL, then select the bulk upload option.

If you do not enter any information for 15 minutes you will be automatically logged off.

How to complete your paper EC Sales List

HMRC must receive your paper EC Sales List within 14 days of the end of the reporting period.

If you need to obtain a paper EC Sales List you can either download form VAT101 or contact HMRC to request one.

Contact HMRC to stop receiving EC Sales Lists.

The EC Sales List header field

Enter all the following on the EC Sales List:

  • your name and address
  • your 9 digit VAT registration number
  • your 3 digit Branch/Subsidiary Identifier number if you have one.
  • the period the list relates to shown as a 4 digit number (the first 2 digits are the month and the last 2 digits are the year, for example, show quarter 1, 2012 as 03 12
  • for monthly submissions show the number of the month from 01 to 12 followed by the last 2 digits of the year, for example, January 2015 would be shown as 01 15

Totals and declaration

The paper EC Sales List - form VAT101 EC Sales List - has 8 lines. If you need to enter more lines you can use form VAT101A EC Sales List Continuation Sheet. The format for entering the information is the same on both forms.

If you also complete form VAT101A you will need to complete the total number of lines completed.

Complete the declaration at the end of form VAT101, and sign and date it. Include a name and phone number in case HMRC needs to contact you.

Data entry

For each customer, enter their country code and their VAT registration number.

If you supplied goods, enter the value (including related costs) of all the goods supplied to that customer (deducting credit notes where appropriate). Leave the indicator column blank.

Related costs include services which form part of the goods, such as freight and insurance costs.

If you were an intermediate supplier in a triangulated sale, enter the total value of the supplies to each customer on a separate line from any other supplies made to that customer. Enter 2 in the indicator column.

If you supplied services on or before 31 December 2020 which were subject to the reverse charge in an EU country, enter the total value of these supplies on a separate line. Enter ‘3’ in the indicator column on the EC Sales List for the fourth quarter of 2020.

Entering the value of supplies

When you enter the value of the supplies you have made to each customer, you:

  • do not include the £ symbol, decimal points or commas
  • round the pence down to the nearest pound
  • enter the value so it ends next to the pence column
  • show a negative figure by entering a minus sign before the amount

Where to send the form

Send the completed and signed form (VAT101) and any continuation sheets (VAT101A) to:

HMRC
ECSL Team
BX9 1QT

You do not need to include a street name, city name or PO box when writing to this address.

Correcting errors on your EC Sales List

You must tell HMRC about any errors and omissions on your EC Sales List where:

  • the error exceeds £100
  • you have quoted an incorrect VAT registration number
  • you have incorrectly stated the type of transaction for example, indicator 2 instead of 0

Correcting your EC Sales List online

If you submit the EC Sales List with errors you can correct them online up to 21 days from the date you originally sent it.

If you submit your EC Sales List by CSV or XML you can still use the online service to correct errors identified at the time of submission. Alternatively, if you decide to submit a new file, you must delete the error lines from your original submission within 21 days, using the ‘Correct declaration errors’ page on the ECSL online service.

In both cases, after 21 days:

  • you will not be able to correct your EC Sales List online
  • HMRC may send you a form VAT104 (EC Sales List Error Report)

If you receive a form VAT104

HMRC will send you a form VAT104 if any errors are found on your submission. It must be returned to HMRC showing the correct information.

Correct your EC Sales List using form VAT101B

If you realise you have made a mistake on your paper EC Sales List after you have sent it to HMRC, you can amend, delete, or add to the information you have already entered using form VAT101B. Send the completed and signed VAT101B to the address shown on the form.

To delete a line

Form VAT101B has 2 lines for each entry, one called ‘old’ and one called ‘new’. To delete a line, enter the details of that line in the old section. Leave the new section empty. Enter the following exactly as they appeared on your original EC Sales List:

  • reporting period
  • country code
  • customer’s VAT number
  • value of supplies
  • indicator

To insert a line left off your original EC Sales List

To insert a new line, enter the details in the new section - leave the old section empty. Enter details of:

  • the reporting period
  • your customer’s country code
  • your customer’s VAT number
  • the value of the supplies you made
  • whether your supplier shipped the goods directly to your customer - enter ‘2’ in the indicator column if they did, or enter ‘3’ for services

To amend a line

To amend a line that you have already declared, enter the original details in the old section. Put the new details in the new section. In the old section, make sure you enter the following details exactly as they appeared on your original EC Sales List:

  • reporting period
  • country code
  • customer’s VAT registration number
  • value of supplies
  • indicator

How to correct your EC Sales List for call-off stock

If you send your EC Sales List for call-off stock to HMRC and then realise that you have made a mistake, email:eslhelpdesk@hmrc.gov.uk team with the following information:

  • the reporting period in question
  • your customer’s 2 letter country code
  • your customer’s VAT registration number
  • details of the mistake

To delete a complete EC Sales List submission contact HMRC in writing to:

HMRC
DMB 613
BX5 5AB

You do not need to include a street name, city name or PO box when writing to this address.

Published 1 July 2014
Last updated 13 January 2021 + show all updates
  1. Change to the date in the 'Overview' section - this now refers to EC Sales Lists for sales made on or before 31 December 2020.

  2. This page has been updated because the Brexit transition period has ended. This guidance is only for sales made on or before 31 December 2020.

  3. Information about call-off stock has been added.

  4. First published.